Question 5

Object

Representation ID: 832

Received: 13/12/2021

Respondent: Mr Richard Williams

Figures over estimated

Object

Representation ID: 852

Received: 13/12/2021

Respondent: Mrs Karen Daker

Why should our greenbelt be used for West Midlands Housing. They have plenty of Brownfield sites to take the 4,000 homes we are having for them .

Object

Representation ID: 858

Received: 13/12/2021

Respondent: Harris Lamb Property Consultancy

Harris Lamb, representing Folks Holdings Ltd considers that insufficient housing has been allocated in locations abutting the Black Country Conurbation and that SHELAAA site 343 can deliver sustainable development to help meet that need

Support

Representation ID: 879

Received: 13/12/2021

Respondent: Cannock Chase Council

Support approach of meeting needs within our boundary and consideration of the needs of the Black Country and Birmingham. Support infrastructure led strategy.

Support

Representation ID: 887

Received: 10/12/2021

Respondent: Bilbrook Parish Council

In general, the preferred options strategy is welcomed. It sets out a clear strategic framework for the
entire district, however there is insufficient understanding of the issues in Bilbrook, specifically concerns relating to site 519 which is not supported.

Object

Representation ID: 888

Received: 10/12/2021

Respondent: Bilbrook Parish Council

Level of growth proposed for Bilbrook would erode its rural character the allocation of site 519 is contrary to national policy as it will see the erosion of the Green Belt and loss of best and most versatile agricultural land. The proposed release of site 519 will detrimentally erode the Green Belt between Bilbrook and the adjacent urban conurbation of the West Midlands, defeating the purpose of the Green Belt.

Support

Representation ID: 892

Received: 07/12/2021

Respondent: Bilbrook Medical Practice

Support housing development within the local area but Section 106 contributions to mitigate the impact of the increased patient population at the practice will be required.

Object

Representation ID: 904

Received: 28/01/2022

Respondent: Cheslyn Hay Parish Council

Dispute the statement that there is greater services and facilities in Cheslyn Hay and Great Wyrley and request clarification regarding what facilities are available in Cheslyn Hay and Great Wyrley that aren't in other parishes. An assessment to establish road, sewer, school and community facility capacity is required, Most villagers meet their needs in Cannock, Walsall, Stafford, Telford and Birmingham.

Support

Representation ID: 908

Received: 10/12/2021

Respondent: Codsall Parish Council

In general, the preferred options strategy is welcomed. It sets out a clear strategic framework for the entire district. However, there are concerns over some of the proposed details.

Object

Representation ID: 925

Received: 10/12/2021

Respondent: Codsall Parish Council

Would be more sustainable to focus more growth at Cross Green and Dunston. Some of the land allocated for employment land should also be considered for housing

Object

Representation ID: 927

Received: 13/12/2021

Respondent: Essington Parish Council

Housing numbers in South Staffordshire, particularly 4000 home contribution to the Black Country are not justified and is untested, Unclear what the 'testing' of South Staffordshire's HMA contribution means in practice. Concern the 35% uplift for Wolverhampton has been added to general housing need. Exceptional Circumstances for removing Linthouse Lane site from the Green Belt do not exist. Land availability in the Black Country, including in Centres (from former office and retail space), has been underestimated by over 5000 homes. Housing supply in South Staffordshire has been underestimated by around 1000 homes from windfall sites, meaning South Staffordshire is oversupplying by 1153 homes. Minimum figures in the plan will see more development delivered. Strategy focuses on directing development to less sustainable locations

Object

Representation ID: 930

Received: 28/01/2022

Respondent: Barry Bond

Proposals for sites in smaller more expensive villages have not been carried forward due to a claimed lack of sustainability. This will create exclusive enclaves of very expensive houses and price young people out.

Wombourne has 7 sites in an overcrowded village subject to development over 40 years. The infrastructure is stretched to the limits and the two main routes in and out of the village are over-crowded and dangerous.

More should be done to retain as many green spaces as possible and make the best use of brownfield land in Wombourne or elsewhere.

Object

Representation ID: 932

Received: 01/02/2022

Respondent: Dan Kinsey

The two main routes in and out of Wombourne are heavily congested and there are regular Road Traffic Collissions, including between the Lloyd Hill island and Wall Heath island on the A449 crossing Swindon Road. There are also numerous small incidents not recorded in police statistics and all of these pressures could potentially become worse with further housing and traffic pressure from new development.

Object

Representation ID: 952

Received: 13/12/2021

Respondent: Gavin Williamson CBE MP

Do not agree with the council’s current plan to take on 4,000 additional dwellings to contribute to the GBHMA shortfall. Subsequently, I do not support this as the starting basis for the Spatial Strategy Policy.
I also do not support the ongoing approach to the district’s freestanding strategic employment sites. I believe the Secretary of State’s approval of the West Midlands Interchange has significantly altered the case for how some of the proposed and earmarked employment sites should be used

Object

Representation ID: 972

Received: 01/02/2022

Respondent: Stafford Borough Council

Supports preferred option of meeting local housing need plus 4,000 new homes towards the Black Country shortfall as the most appropriate approach, noting the West Midlands Green Belt and need to minimise infrastructure implications for neighbouring areas. Also consider preferred approach appropriate in terms of addressing the employment land provision. Supports the balance of development across Tier 1-3 villages based on access to services.

Nevertheless, significant concerns are raised regarding the urban extension South of Stafford. This does not appear consistent with Strategic Objective 2 as it is not a sustainable approach to meeting Birmingham's housing needs and there are other more sustainable sites in South Staffordshire/adjacent to the Black Country. The site has not demonstrated it would provide appropriate infrastructure to mitigate its impact on roads, schools and leisure in Stafford.

Object

Representation ID: 977

Received: 01/12/2021

Respondent: Kinver Parish Council

South Staffordshire's own housing number at almost 5000 dwellings is too high and should be recalculated. Supply has been underestimated - windfall allowance of 30 dph is far too low, allocated sites typically achieve 25-50% higher numbers than those allocated, should use updated ONS population estimates. Plan is excessively pro growth counter to sustainability, green belt and climate change policies. 4000 contribution to GBHMA needs is too high and should be revisited. 35% uplift for Wolverhampton intended to revitilise urban areas and should not be exported to rural areas. There is sufficient non Green Belt land to meet local need so exceptional circumstances have not been met. Biodiversity net gain will not compensate for this loss. Sites should be released slowly with Green Belt release last

Support

Representation ID: 983

Received: 10/12/2021

Respondent: Lichfield District Council

Noted that the Council is seeking to contribute towards unmet needs of the wider FEMA. Lichfield DC are unable to assist in meeting any unmet employment land need.

Support

Representation ID: 991

Received: 10/12/2021

Respondent: Lapley, Stretton and Wheaton Aston Parish Council

The preferred options is a welcomed documents which sets out a clear strategic framework for the district.
The methodology used to determine the number of houses that should be offered to alleviate the short fall in neighbouring counties appears sound and the number of dwellings appropriate. However, taking land from the green belt should be taken once all other options, ie brown field sites and areas for regeneration, in neighbouring authorities have been exhausted.

Support

Representation ID: 999

Received: 13/12/2021

Respondent: Wolverhampton City Council

Support for the preferred housing growth option of local housing need plus 4,000 homes to meet Greater Birmingham and Black Country Housing Market Area (HMA) need up to 2038 but request full 4,000 homes are attributed to the Black Country.

Support

Representation ID: 1006

Received: 13/12/2021

Respondent: Cameron Homes Ltd

Agent: Pegasus Group

Generally support proposed spatial strategy. The Rural Services and Facilities Audit clearly supports Coven as a Tier 3 settlement.

Support

Representation ID: 1014

Received: 13/12/2021

Respondent: Gladman

Agent: Gladman

Gladman support South Staffordshire District Council's proposal to deliver a minimum of 8,881 dwellings over the plan period of 2018 to 2038, as it represents a significant uplift above the minimum housing requirement set by standard method in accordance with national planning guidance. Gladman express confidence within South Staffordshire District Council to meet the affordable housing need identified in the SHMA (Strategic Housing Market Assessment).

Object

Representation ID: 1015

Received: 13/12/2021

Respondent: Gladman

Agent: Gladman

Gladman consider that the level of surplus land falls slightly short of what would be required to ensure the Local Plan Review remains robust over the plan period. To enhance the deliverability of the Local Plan Review, Gladman recommend that the surplus in supply is should be increased, in this instance, to at 15-20% of the
proposed housing requirement therefore, it may be necessary to allocate additional sites which could achieve a higher site density in turn accordance to accommodate additional dwelling, to achieve the increase to 15-20%.

Support

Representation ID: 1018

Received: 13/12/2021

Respondent: Gladman

Agent: Gladman

Gladman support the spatial strategy detailed in policy DS3, recognising the pattern of development is focused on locating the bulk of new development at the District’s most accessible and sustainable locations. The proposed spatial strategy ensures that new housing will be
accommodated proportionately across the district, resulting in less pressure on infrastructure in any one area, promoting housing delivery through increased choice in location, and ensuring that the development needs and sustainability requirements of the district’s rural settlements are sensitively considered.

Object

Representation ID: 1021

Received: 13/12/2021

Respondent: Gladman

Agent: Gladman

Gladman suggest further consideration should be given to whether non-greenbelt location could accommodate a larger scale of growth, thereby minimising alteration to the green belt boundaries.

Support

Representation ID: 1022

Received: 10/12/2021

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Support Penkridge as Tier 1 settlement including the allocation of land at Cherrybook Drive which is sustainable, suitable, available and deliverable for development within the first 5 years of the plan.

Object

Representation ID: 1029

Received: 13/12/2021

Respondent: Hallam Land Management

Agent: Acres Land & Planning

It would be more logical to use 2018 GL Hearn/Wood report for starting point to choosing sites as this has been prepared at a strategic level using objective criteria for entire conurbation thus removing elements of subjectivity.
Concerns that the infrastructure led strategy is driving choice of GB sites over more sensitive sites with the consequence that more sensitive, logical GB sites that align better with GB policy are omitted.
The Strategy is over-reliant on a small number of large sites such as Strategic Allocations at Cross Green (Policy SA2), Linthouse Lane (SA3) and land east of Bilbrook which may be slow to delivery and thus undermine targets.
GBBCHMA shortfall appears to have increased since shortfallw as initially identified. Recent studies by Barton Willmore and Turley have shown much higher levels of housing shortfall that has not been tested by the Council. 4,000 homes offered may not be enough.
The offer of 4,000 is minimal and there should be discussion as to varying levels of housing provision. The Standard method is also set to be reviewed with housing provision diverted to areas promoted for "levelling up" such as the midlands - thus increasing housing targets. This should be kept under review and change if necessary.
Consent for SRFI at Four Ashes and growth of i54 is likely to boost housing need beyond Standard Method target. Greater pressure for larger (and higher quantity of) homes due to working from home patterns continued post-Covid.
Assessment for permission lapses (eg. 5-10%) needs to be had and an allowance for sites granted/delivered outside of plan period.
Not content with level of housing allocated for Codsall/Bilbrook as its level of provision has fallen back proportionately compared to Penkridge and some other settlements since the Issues and Options plan.
Do not support the proposed direction of growth on the edge of Bilbrook/Codsall which does not conform to advice in Greater Birmingham HMA Study where growth would occur to the north of Codsall. The Council's proposed distribution conflicts with the technical advice on GB criteria.

Support

Representation ID: 1049

Received: 08/02/2022

Respondent: Staffordshire County Council

P33 - 39 – Housing development outside of 2/3mile school walking catchments may increase strain on the public purse through provision of extra education costs, that may not be sustainable. SSDC should consider whether growth in such areas is sustainable. Detailed comments are provided setting out where likely school capacity improvements would be required to address school place capacity issues as a result of new development.
P51 – The 5 tier classification is appropriate to achieve the necessary housing and employment growth in the District. Additional landscape enhancement could offset the additional road travel resulting from expanding Tier 1 & 2 settlements. A strategic plan to enhance the setting of roads through tree and woodland planting would help to integrate new development into the changing landscape. The plan should support the significant changes the farmed landscape is likely to undergo during the plan period.

Support

Representation ID: 1059

Received: 08/02/2022

Respondent: Cannock Chase AONB

The AONB boundary should be indicated on the map for Locality 1.

Support

Representation ID: 1068

Received: 09/12/2021

Respondent: St Philips

Agent: Pegasus Group

No in principle objection to the spatial strategy.

Object

Representation ID: 1077

Received: 08/02/2022

Respondent: CPRE Staffordshire

- The housing target is far in excess of standard method required by government due to the contribution to the Black Country– CPRE questions the scale of the overspill from the Black Country and ask this to be reviewed. Upcoming planning reforms mean it is uncertain if the Duty to Cooperate will be retained.
- Windfalls are artificially low and should be increased to 100 DPA (1,500 over plan period) to reflect historic averages.
- The 4,000 contribution to the Black Country/HMA shouldn’t be reflected in the five year supply as it risks the Council being unable to demonstrate a five year supply in future.
- South Staffordshire should agree with the Black Country that no greenfield development will be allowed before brownfield sites in the Black Country are built out
- Request that explicit allocations should be made for the Black Country vs those made to meet South Staffordshire’s needs
- The over allocation for plan flexibility should be removed, it is not defensible to use it in case of development not coming forward on allocated sites
- Stafford has not requested its unmet needs be met and has previously objected to growth South of Stafford
- Suggest that housing targets are incorrectly calculated and could be reduced